- 2 - (1) Whether the amount assessed in each year at issue was correct; (2) whether petitioner’s April 7, 1994, bankruptcy filing barred the assessment of his 1994 income tax liability; (3) whether the assessments for the tax years at issue were timely; (4) whether penalties under section 6651(a)(2) should be abated; (5) whether interest on the tax liabilities for all tax years at issue should be abated; (6) whether petitioner received proper notice of the filing of the NFTL; and (7) whether collection alternatives were properly considered. FINDINGS OF FACT Petitioner resided in Torrance, California, when he filed the petition. Prior to becoming a California resident, he was a resident of New Orleans, Louisiana. Petitioner filed tax returns in which he reported income of $37,353 for 1992, $12,265 for 1993, and $8,123 for 1994, and income taxes due of $4,924.32, $2,874.95, and $1,133.74, for those respective years. Petitioner failed to pay the income taxes due other than a partial payment of $156 for 1994. Respondent assessed petitioner's 1992-94 Federal income tax liabilities on September 20, 1993, August 5, 1996, and October 9, 1995, respectively. The assessment for each tax year was made within 3 years from the date the return for that year was filed. Petitioner filed for bankruptcy on three separate occasions: The bankruptcy proceeding filed on April 7, 1994, was dismissedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011